How to Comply with the 2020 GIPS Standards

Matt Deatherage, CFA, CIPM
Partner
April 23, 2020
15 min
How to Comply with the 2020 GIPS Standards

A new decade is upon us and with the new decade comes a series of new requirements in terms of investment performance reporting for firms and asset owners that elect to claim compliance with the GIPS standards.

Many organizations have elected to adopt the 2020 edition of the GIPS standards early and have already put a solid foundation in place for the updated requirements; however, many organizations have not. The adoption deadline for all compliant organizations is rapidly approaching, so if your organization has not begun this conversion, now is the time to get started.

What is Changing and Why

It has been over a decade since the last edition of the GIPS standards was released, and quite frankly, the industry has changed since 2010. As the industry has evolved, CFA Institute has released a number of Q&A’s, guidance statements, and interpretations on how the changes in the industry impact the standards.

Ten years of updates have resulted in a vast repository of information needed to obtain the guidance required to comply. Having so many different resources for guidance (the 2010 GIPS Handbook, separate guidance statements, the Q&A database, and the GIPS Help Desk) has made managing the requirements of GIPS a pretty daunting task; thus, one of the goals of the 2020 standards is to centralize all of the updates that have come out over the past ten years. The 2020 GIPS standards consolidates many of the concepts previously addressed in guidance statements and Q&A’s, allowing the new provisions and explanation of the provisions to serve as the primary source that firms, asset owners, verifiers, and consultants can look to for guidance.

Additionally, the 2010 standards were heavily focused on composites and the traditional definition of prospective clients. Using this as the main framework is not always applicable to organizations that primarily manage pooled funds or asset owners that do not compete for business or report performance to prospective clients. To address this, CFA Institute set out to make this new edition of the standards more applicable to pooled fund managers and asset owners. These updates were designed to make claiming compliance easier and more relevant for these types of managers, while not creating additional burdens on organizations that are already compliant with GIPS. This goal is evident in the new format of the provisions, which separately focuses on requirements for investment firms, asset owners, and verifiers.

In addition to the separation of pooled funds and composites, the guidance is broader on when organizations may present money-weighted returns instead of time-weighted returns. This change now allows the decision to be based on the investment vehicle structure and who controls the timing and amount of external cash flows, rather than limiting money-weighted returns to certain asset classes. This is a welcomed update in the industry as many organizations were frustrated by requirements to calculate and present time-weighted returns when this type of return was not the most meaningful representation of how they managed their investment strategies.

How the 2020 GIPS Standards are Organized

For ease of use and navigation, the 2020 GIPS standards is broken out into three different groups of tailored provisions – firms, asset owners, and verifiers. Each containing specific requirements and recommendations applicable for that type of organization.

As an organization claiming compliance or working to become compliant for the first time, you will need to determine whether the set of requirements for firms or assets owners is applicable to your claim of compliance. The primary distinguishing factor is whether your organization competes for business and manages external money, or reports to an oversight board and manages internal money. The answer to this determines which set of tailored provisions should be followed and sets the framework for how the standards will apply. 

Where to Start – GIPS Compliance Updates

Regardless of whether you are excited for the updates to the standards, they are coming and will be required for all firms and asset owners claiming compliance with GIPS. The new requirements take effect once your GIPS Reports (formerly called Compliant Presentations) present performance information that is inclusive of the period 31 December 2020.

There is a lot of information available and dissecting everything that has been released can be overwhelming. For organizations that have never claimed compliance, the good news is that the new standards are more applicable and easier to adopt than they were previously.

For most organizations currently claiming compliance, what’s great is that the new standards do not require a lot of changes, rather they mostly provide optional procedures that you may choose to adopt if you find it beneficial to do so. However, some firms will require more work.

At Longs Peak, we have created the following questionnaire designed to help you determine if converting to the 2020 GIPS standards will require more than a few minor tweaks. This list does not include all changes, but includes the top ten material changes that may require a project plan to implement the required changes by the effective date of the 2020 GIPS standards.

Answering “Yes” to any of the following questions means your organization may require more than a few quick tweaks to implement the 2020 changes:

GIPS 2020 Checklist 

  1. Does your firm have limited distribution pooled funds (i.e., private funds that are not regulated under a framework that would permit the general public to purchase shares in the fund without a one-on-one presentation)?
  2. Has your firm created single account composites for pooled funds solely for the purpose of meeting the GIPS requirement of having every discretionary, fee-paying portfolio in at least one composite?
  3. Does your firm have multi-strategy portfolios (e.g., balanced portfolios where the equity and fixed income segments each could be represented as standalone strategies) where you would like to carve-out the individual strategies into their own composites?
  4. Does your firm have portfolios where actual transaction costs are unavailable (e.g., wrap accounts or other bundled fee arrangements) and you would like to estimate transaction costs to show gross-of-fee returns without labeling the returns as supplemental information?
  5. Does your firm have portfolios where your firm controls the amount and timing of external cash flows (other than for private equity or real estate) and you would like to present money-weighted returns rather than time-weighted returns?
  6. Does your firm have real estate or private equity composites?
  7. Does your firm include theoretical performance (e.g., model performance) as part of a GIPS report?
  8. Does your firm follow the Advertising Guidelines to claim compliance with the GIPS standards outside of your GIPS Reports?
  9. Does your firm currently update your GIPS compliant presentations more than 12 months after the year ends?
  10. Does your firm have advisory-only assets or uncalled committed capital you wish to present in your GIPS Report?

Although the intent is for the adoption of the standards to be more relevant, many organizations find themselves asking “where do I even begin?” The great news is that you don’t have to figure this all out on your own.

At Longs Peak, we have spent countless hours familiarizing ourselves with the new standards and have helped all of our clients begin to adopt the changes. We know what issues come up and how to navigate the changes required.

As a consultant, we do not have independence requirements like your verifier, so we can actually help you implement many of the 2020 changes required for your organization. If you do not already work with a GIPS consultant, now may be a good time to consider hiring one, especially if you lack the resources needed to get this done by the deadline to convert to the 2020 GIPS standards.

Contact us if you do not wish to read through all of the requirements and recommendations to identify what actions are required for your organization.

Finally, if you would like to read more about what changed and why, we have summarized the main changes to the GIPS standards in GIPS 2020 What’s Changing and What you Should Do.

Recommended Post

View All Articles

Key Takeaways from the 29th Annual GIPS® Standards Conference in Phoenix

The 29th Annual Global Investment Performance Standards (GIPS®) Conference was held November 11–12, 2025, at the Sheraton Grand at Wild Horse Pass in Phoenix, Arizona—a beautiful desert resort and an ideal setting for two days of discussions on performance reporting, regulatory expectations, and practical implementation challenges. With no updates released to the GIPS standards this year, much of the content focused on application, interpretation, and the broader reporting and regulatory environment that surrounds the standards.

One of the few topics directly tied to GIPS compliance with a near-term impact relates to OCIO portfolios. Beginning with performance presentations that include periods through December 31, 2025, GIPS compliant firms with OCIO composites must present performance following a newly prescribed, standardized format. We published a high-level overview of these requirements previously.

The conference also covered related topics such as the SEC Marketing Rule, private fund reporting expectations, SEC exam trends, ethical challenges, and methodology consistency. Below are the themes and observations most relevant for firms today.

Are Changes Coming to the GIPS Standards in 2030?

Speakers emphasized that while no new GIPS standards updates were introduced this year, expectations for consistent, well-documented implementation continue to rise. Many attendee questions highlighted that challenges often stem more from inconsistent application or interpretation than from unclear requirements.

Several audience members also asked whether a “GIPS 2030” rewrite might be coming, similar to the major updates in 2010 and 2020. The CFA Institute and GIPS Technical Committee noted that:

    ·   No new version of the standards is currently in development,

     ·   A long-term review cycle is expected in the coming years, and

     ·   A future update is possible later this decade as the committee evaluates whether changes are warranted.

For now, the standards remain stable—giving firms a window to refine methodologies, tighten policies, and align practices across teams.

Performance Methodology Under the SEC Marketing Rule

The Marketing Rule featured prominently again this year, and presenters emphasized a familiar theme: firms must apply performance methodologies consistently when private fund results appear in advertising materials.

Importantly, these expectations do not come from prescriptive formulas within the rule. They stem from:

1.     The “fair and balanced” requirement,

2.     The Adopting Release, and

3.     SEC exam findings that view inconsistent methodology as potentially misleading.

Common issues raised included: presenting investment-level gross IRR alongside fund-level net IRR without explanation, treating subscription line financing differently in gross vs. net IRR, and inconsistently switching methodology across decks, funds, or periods.

To help firms void these pitfalls, speakers highlighted several expectations:

     ·   Clearly identify whether IRR is calculated at the investment level or fund level.

     ·   Use the same level of calculation for both gross and net IRR unless a clear, disclosed rationale exists.

     ·   Apply subscription line impacts consistently across both gross and net.

     ·   Label fund-level gross IRR clearly, if used(including gross returns is optional).

     ·   Ensure net IRR reflects all fees, expenses, and carried interest.

     ·   Disclose any intentional methodological differences clearly and prominently.

     ·   Document methodology choices in policies and apply them consistently across funds.

This remains one of the most frequently cited issues in SEC exam findings for private fund advisers. In short: the SEC does not mandate a specific methodology, but it does expect consistent, well-supported approaches that avoid misleading impressions.

Evolving Expectations in Private Fund Client Reporting

Although no new regulatory requirements were announced, presenters made it clear that limited partners expect more transparency than ever before. The session included an overview of the updated ILPA reporting template along with additional information related to its implementation. Themes included:

     ·   Clearer disclosure of fees and expenses,

     ·   Standardized IRR and MOIC reporting,

     ·   More detail around subscription line usage,

     ·   Attribution and dispersion that are easy to interpret, and

     ·   Alignment with ILPA reporting practices.

These are not formal requirements, but it’s clear the industry is moving toward more standardized and transparent reporting.

Practical Insights from SEC Exams—Including How Firms Should Approach Deficiency Letters

A recurring theme across the SEC exam sessions was the need for stronger alignment between what firms say in their policies and what they do in practice. Trends included:

     ·   More detailed reviews of fee and expense calculations, especially for private funds,

     ·   Larger sample requests for Marketing Rule materials,

     ·   Increased emphasis on substantiation of all claims, and

     ·   Close comparison of written procedures to actual workflows.

A particularly helpful part of the discussion focused on how firms should approach responding to SEC deficiency letters—something many advisers encounter at some point.

Christopher Mulligan, Partner at Weil, Gotshal & Manges LLP, offered a framework that resonated with many attendees. He explained that while the deficiency letter is addressed to the firm by the exam staff, the exam staff is not the primary audience when drafting the response.

The correct priority order is:

1. The SEC Enforcement Division

Enforcement should be able to read your response and quickly understand that: you fully grasp the issue, you have corrected or are correcting it, and nothing in the finding merits escalation.

Your first objective is to eliminate any concern that the issue rises to an enforcement matter.

2. Prospective Clients

Many allocators now request historical deficiency letters and responses during due diligence. The way the response is written—its tone, clarity, and thoroughness—can meaningfully influence how a firm is perceived.

A well-written response shows strong controls and a culture that takes compliance seriously.

3. The SEC Exam Staff

Although examiners issued the letter, they are the third audience. Their primary interest is acknowledgment and a clear explanation of the remediation steps.

Mulligan emphasized that firms often default to writing the response as if exam staff were the only audience. Reframing the response to keep the first two audiences in mind—enforcement and prospective clients—helps ensure the tone, clarity, and level of detail are appropriate and reduces both regulatory and reputational risk.

Final Thoughts

With no changes to the GIPS standards introduced this year, the 2025 conference in Phoenix served as a reminder that the real challenges involve consistency, documentation, and communication. OCIO providers in particular should be preparing for the upcoming effective date, and private fund managers continue to face rising expectations around transparent, well-supported performance reporting.

Across all sessions, a common theme emerged: clear methodology and strong internal processes are becoming just as important as the performance results themselves.

This is exactly where Longs Peak focuses its work. Our team specializes in helping firms document and implement practical, well-controlled investment performance frameworks—from IRR methodologies and composite construction to Marketing Rule compliance, fee and expense controls, and preparing for GIPS standards verification. We take the technical complexity and turn it into clear, operational processes that withstand both client due diligence and regulatory scrutiny.

If you’d like to discuss how we can help strengthen your performance reporting or compliance program, we’d be happy to talk. Contact us.

From Compliance to Growth: How the GIPS® Standards Help Investment Firms Unlock New Opportunities

For many investment managers, the first barrier to growth isn’t performance—it’s proof.
When platforms, consultants, and institutional investors evaluate new strategies, they’re not just asking how well you perform; they’re asking how you measure and present those results.

That’s where the GIPS® standards come in.

More and more investment platforms and allocators now require firms to comply with the GIPS standards before they’ll even review a strategy. For firms seeking to expand their reach—whether through model delivery, SMAs, or institutional channels—GIPS compliance has become a passport to opportunity.

The Opportunity Behind Compliance

Becoming compliant with the GIPS standards is about more than checking a box. It’s about building credibility and transparency in a way that resonates with today’s due diligence standards.

When a firm claims compliance with the GIPS standards, it demonstrates that its performance is calculated and presented according to globally recognized ethical principles—ensuring full disclosure and fair representation. This helps level the playing field for managers of all sizes, giving them a chance to compete where it matters most: on results and consistency.

In short, GIPS compliance doesn’t just make your reporting more accurate—it makes your firm more credible and discoverable.

Turning Complexity Into Clarity

While the benefits are clear, the process can feel overwhelming. Between defining the firm, creating composites, documenting policies and procedures, and maintaining data accuracy—many teams struggle to find the time or expertise to get it right.

That’s where Longs Peak comes in.

We specialize in simplifying the process. Our team helps firms navigate every step—from initial readiness and composite construction to quarterly maintenance and ongoing training—so that compliance becomes a seamless part of operations rather than a burden on them.

As one of our clients put it, “Longs Peak helps us navigate GIPS compliance with ease. They spare us from the time and effort needed to interpret what the requirements mean and let us focus on implementation.”

Real Firms, Real Impact

We’ve seen firsthand how GIPS compliance can transform firms’ growth trajectories.

Take Genter Capital Management, for example. As David Klatt, CFA and his team prepared to expand into model delivery platforms, managing composites in accordance with the GIPS standards became increasingly complex. With Longs Peak’s customized composite maintenance system in place, Genter gained the confidence and operational efficiency they needed to access new platforms and relationships—many of which require firms to be GIPS compliant as a baseline.

Or consider Integris Wealth Management. After years of wanting to formalize their composite reporting, they finally made it happen with our support. As Jenna Reynolds from Integris shared:

“When I joined Integris over seven years ago, we knew we wanted to build out our composite reporting, but the complexity of the process felt overwhelming. Since partnering with Longs Peak in 2022, they’ve been instrumental in driving the project to completion. Our ongoing collaboration continues to be both productive and enjoyable.”

These are just two examples of what happens when compliance meets clarity—firms gain time back, confidence grows, and new business doors open.

Why It Matters—Compliance as a Strategic Advantage

At Longs Peak, we believe compliance with the GIPS standards isn’t a cost—it’s an investment.

By aligning your firm’s performance reporting with the GIPS standards, you gain:

  • Access to platforms and institutions that require GIPS compliant firms.
  • Credibility and trust in an increasingly competitive landscape.
  • Operational efficiency through consistent data and documented processes.
  • Scalability to support multiple strategies and distribution channels.

Simply put: compliance fuels confidence—and confidence drives growth.

Simplifying the Complex

At Longs Peak, we’ve helped over 250 firms and asset owners transform how they calculate, present, and communicate their investment performance. Our goal is simple: make compliance with the GIPS standards practical, transparent, and aligned with your firm’s growth goals.

Because when compliance works efficiently, it doesn’t slow your business down—it helps it reach further.

Ready to turn compliance into a growth advantage?

Let’s talk about how we can help your firm simplify the complex.

📧 hello@longspeakadvisory.com
🌐 www.longspeakadvisory.com

Performance reporting has two common pitfalls: it’s backward-looking, and it often stops at raw returns. A quarterly report might show whether a portfolio beat its benchmark, but it doesn’t always show why or whether the results are sustainable. By layering in risk-adjusted performance measures—and using them in a structured feedback loop—firms can move beyond reporting history to actively improving the future.

Why a Feedback Loop Matters

Clients, boards, and oversight committees want more than historical returns. They want to know whether:

·        performance was delivered consistently,

·        risk was managed responsibly, and

·        the process driving results is repeatable.

A feedback loop helps firms:

·        define expectations up front instead of rationalizing results after the fact,

·        monitor performance relative to objective appraisal measures,

·        diagnose whether results are consistent with the manager’s stated mandate, and

·        adjust course in real time so tomorrow’s outcomes improve.

With the right discipline, performance reporting shifts from a record of the past toa tool for shaping the future.

Step 1: Define the Measures in Advance

A useful feedback loop begins with clear definitions of success. Just as businesses set key performance indicators (KPIs) before evaluating outcomes, portfolio managers should define their performance and risk statistics in advance, along with expectations for how those measures should look if the strategy is working as intended.

One way to make this tangible is by creating a Performance Scorecard. The scorecard sets out pre-determined goals with specific targets for the chosen measures. At the end of the performance period, the manager completes the scorecard by comparing actual outcomes against those targets. This creates a clear, documented record of where the strategy succeeded and where it fell short.

Some of the most effective appraisal measures to include on a scorecard are:

·        Jensen’s Alpha: Did the manager generate returns beyond what would be expected for the level of market risk (beta) taken?

·        Sharpe Ratio: Were returns earned efficiently relative to volatility?

·        Max Drawdown: If the strategy claims downside protection, did the worst loss align with that promise?

·        Up- and Down-Market Capture Ratios: Did the strategy deliver the participation levels in up and down markets that were expected?

By setting these expectations up front in a scorecard, firms create a benchmark for accountability. After the performance period, results can be compared to those preset goals, and any shortfalls can be dissected to understand why they occurred.

Step 2: Create Accountability Through Reflection

This structured comparison between expected vs. actual results is the heart of the feedback loop.

If the Sharpe Ratio is lower than expected, was excess risk taken unintentionally? If the Downside Capture Ratio is higher than promised, did the strategy really offer the protection it claimed?

The key is not just to measure, but to reflect. Managers should ask:

·        Were deviations intentional or unintentional?

·        Were they the result of security selection, risk underestimation, or process drift?

·        Do changes need to be made to avoid repeating the same shortfall next period?

The scorecard provides a simple framework for this reflection, turning appraisal statistics into active learning tools rather than static reporting figures.

Step 3: Monitor, Diagnose, Adjust

With preset measures in place, the loop becomes an ongoing process:

1.     Review results against the expectations that were defined in advance.

2.     Flag deviations using alpha, Sharpe, drawdown, and capture ratios.

3.     Discuss root causes—intentional, structural, or concerning.

4.     Refine the investment process to avoid repeating the same shortcomings.

This approach ensures that managers don’t just record results—they use them to refine their craft. The scorecard becomes the record of this process, creating continuity over multiple periods.

Step 4: Apply the Feedback Loop Broadly

When applied consistently, appraisal measures—and the scorecards built around them—support more than internal evaluation. They can be used for:

·        Manager oversight: Boards and trustees see whether results matched stated goals.

·        Incentive design: Bonus structures tied to pre-defined risk-adjusted outcomes.

·        Governance and compliance: Demonstrating accountability with clear, documented processes.

How Longs Peak Can Help

At Longs Peak, we help firms move beyond static reporting by building feedback loops rooted in performance appraisal. We:

·        Define meaningful performance and risk measures tailored to each strategy.

·        Help managers set pre-determined expectations for those measures and build them into a scorecard.

·        Calculate and interpret statistics such as alpha, Sharpe, drawdowns, and capture ratios.

·        Facilitate reflection sessions so results are compared to goals and lessons are turned into process improvements.

·        Provide governance support to ensure documentation and accountability.

The result is a sustainable process that keeps strategies aligned, disciplined, and credible.

Closing Thought

Markets will always fluctuate. But firms that treat performance as a feedback loop—nota static report—build resilience, discipline, and trust.

A well-structured scorecard ensures that performance data isn’t just about yesterday’s story. When used as feedback, it becomes a roadmap for tomorrow.

Need help creating a Performance Scorecard? Reach out if you want us to help you create more accountability today!